A compliance officer who suspects ongoing securities fraud within their firm but fails to escalate the matter to senior leadership or regulators may be found liable under the theory of:
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A
Respondeat superior, because the firm is always liable for employee conduct
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B
Aiding and abetting or supervisory liability for failing to prevent or stop the violation
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C
Negligent hiring if the fraudster was improperly vetted
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D
Strict liability regardless of the compliance officer's knowledge or intent